Brokerage
A broker who handles sales for clients is a designated non-financial business (DNFBP) under the UAE's anti-money laundering law. The exam tests the 2025 regime that replaced the 2018 law, the three Real Estate Activity Report triggers, beneficial owners, PEPs, suspicious transaction reports, tipping off, five-year record keeping and sanctions freezes.
Brokerage practice, ethics and compliance7 min read7 sections
AML questions are mostly applied: a cash buyer, a company with nominees, a PEP's relative, a crypto payment, a client who asks whether you reported him. Each one turns on knowing which report applies, who the beneficial owner is, or what you must not say.
| Item | Current position (as at 12 Oct 2026) | Replaced |
|---|---|---|
| Law | Federal Decree-Law No. 10 of 2025, in force 14 Oct 2025 | Federal Decree-Law No. 20 of 2018 |
| Executive regulations | Cabinet Decision No. 134 of 2025, in force 14 Dec 2025 | Cabinet Decision No. 10 of 2019 |
| Supervisor of mainland brokers | Ministry of Economy & Tourism | Same ministry, renamed |
Every note. Every question. One pass.
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| Reports received by | UAE Financial Intelligence Unit, via goAML | Unchanged |
| Sanctions coordinator | EOCN, under Cabinet Resolution No. 74 of 2020 | Unchanged |
A broker is a DNFBP when carrying out purchase or sale transactions for clients; the activity, not the licence label, is the trigger. A DNFBP must assess its risks, adopt controls, appoint a compliance officer, train staff, carry out due diligence, register on goAML, report, screen for sanctions and keep records.
The 2025 law widened the regime: proliferation financing is a standalone offence, evasion of direct and indirect taxes (such as VAT) is a predicate offence, funds include digital and encrypted assets, and money laundering proceedings and penalties do not lapse with time. Dubai's Bylaw No. 85 of 2006 adds that a broker may not facilitate any transaction that breaks the law (Art. 18) and must keep a register of transactions and give the parties true copies on request (Art. 15).
